The group has a total expenditure of 18 million 500 thousand yuan due to its advertising and publicity expenses, which can not be deducted before tax and pay more than 6 million 105 thousand yuan of income tax.

In 2001, the group set up an independent pfer station responsible for the final sale of the factory's cigarettes.

That is to say, the tobacco factory sells cigarettes to the allocation stations according to the approved price approved by the tax authorities, and then sells them from the allocation stations to various places. The allocation station is actually an independent sales company.

Because cigarette factories and pfer stations are affiliated enterprises, the profits of the allocation stations can be controlled to almost zero, that is, the sales profits of the pfer stations are almost zero, without paying much income tax after deducting advertising, business publicity, hospitality and personnel wages.

For this reason, it is assumed that the sales income of the pfer station in 2001 is still 2 billion 200 million yuan, and the sales revenue of the cigarette factory is 2 billion 125 million 300 thousand yuan, that is, the cigarette factory sells cigarettes to the pfer station at a total price of 2 billion 125 million 300 thousand yuan.

In this way, the purchase and sale links have been formed between the cigarette factories and the pfer stations. According to the relevant laws and regulations of the value-added tax, such sales shall be subject to value-added tax, but because the value added tax is a turnover tax, and the price of the cigarettes sold abroad remains unchanged, and the added value of the total value remains unchanged, the value-added tax and urban construction tax paid by the cigarette factories and the pfer stations will not increase, so the impact of the value-added tax and the urban construction tax will not be considered here.

Through the intermediate link of the pfer station, the station can deduct the "three charges" of the independent expenditure which can be deducted from the above analysis, and the cigarette factory also independently does the image advertisement and the business propaganda. It deducts the "three charges" as follows: the advertising fee can actually deduct the limit to 42 million 510 thousand yuan (212530 * 2%); the business entertainment expense may deduct the limit to be 6 million 410 thousand yuan; the business propaganda expense may actually deduct the limit to 10 million 630 thousand yuan (212530 5 5).

It is assumed that in 2001, the cigarette factory and the pfer station quot; three fee "to maintain the level unchanged in 2000, through reasonable apportionment", "three charges" can not be deducted from the deduction limit, and the income tax is exempt from 6 million 105 thousand yuan.

However, because of the sales relationship between the cigarette factory and the pfer station, the stamp duty will not be considered in addition to the value-added tax and urban construction tax. Because there is a sales relationship, it is necessary to pay a stamp duty of 1 million 280 thousand yuan (212530 x 0.0003 x 2). For the additional education fee, the education fee of the cigarette industry is 1.5% of the turnover tax, and the pfer station is a commercial unit. The education fee is added to 3% of the turnover tax, and two of the 1.5% are different.

Through the above analysis, we can calculate whether the allocation stations need to exist independently.

Suppose that the net profit of the net income of the 5 barium and the diameter of the "three fee" will be equal to the net profit of the less paid income tax.

(x 17% x 1.5%) x 67%; the net profit of the "three fee" increase of multiple columns is: [2%X + 5% X + 1500 * 5 5 + (X 1500) x 3 3) * 33%, after a simplified introduction: [0.0006Y + Y (X Y) x], = = (+ + 0.028X), (+ + 0.028X) for more charges, then when the tobacco factory is at the same time, if the expenditure exceeds the limit and is greater than [+ + (2 -)), the pfer station has the necessity of independent existence, otherwise, it is unnecessary. That is: the net profit of stamp duty and education fee decrease is: [0.0003Y * 2 + (X Y).

We will use the formula in the above example to find out that [0.0006Y + 0.00255 (X Y) * 0.67] 0.33 = 2 million 970 thousand yuan, the "three fee" expenditure of the cigarette factory exceeds 18 million 70 thousand yuan, greater than 2 million 970 thousand yuan, so an independent pfer station should be set up.

This article analyses whether it is necessary to set up a tobacco factory, and how to retain the pfer station. However, the analysis method is also applicable to other enterprises that set up independent sales companies, but only according to specific taxes and tax rates.